Kowal v. Hofher

Kowal v. Hofher, 181 Conn. 355, 436 A.2d 1 (1980) establishes that 30-102 is not an exclusive remedy. "There is absolutely no indication, however, that where causation is adequately traced back to the barkeeper who served an intoxicated person an alcoholic beverage the legislature, nevertheless, intended the dram shop act to be the injured plaintiff's exclusive remedy. . . . If the plaintiff has no cause of action against the bartender for negligence, it is not the statute but rather the common law which denies the plaintiff a right of recovery." Id. Kowal recognized an action for wanton and reckless misconduct.